SECURE 2.0 & ESG

Defined Contribution Quarterly 1Q 2023

January 31, 2023 | 7 Minutes Read

Quarterly Snapshot

Target date fund outflows were higher compared to the quarter prior, while plan participants continue to seek lower market volatility in money market funds during challenging market conditions. In 2022, active manager outperformance generally has been seen in US equities, most pronounced in large cap value, small cap and emerging market equity.

Net Target Date Fund Investment Flows

Source: Strategic Insight, Simfund. As of December 31, 2022. For open-end mutual funds only. For illustrative purposes only.

Net New Investment Flows

Source: ICI “The U.S. Retirement Market, Third Quarter 2022.” As of Q3 2022 (latest available). For illustrative purposes only.

Asset Class Performance

Source: Morningstar. As of December 31, 2022. Past performance does not guarantee future results, which may vary. For illustrative purposes only.

Active Management Performance

Source: Morningstar. As of December 31, 2022. Net of fees. Please refer to the disclosures for benchmarks. Past performance does not guarantee future results, which may vary. For illustrative purposes only.

In Focus: ESG in ERISA Plans

On November 22, 2022, the Department of Labor (DOL) released a final rule on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights, clarifying how ERISA’s fiduciary duties of prudence and loyalty apply to selecting investments and exercising shareholder rights. The final rule allows plan fiduciaries to consider climate change and other environmental, social and governance factors when making investment decisions where relevant to a risk and return analysis or used as a tiebreaker in certain circumstances. The final rule generally becomes January 30, 2023, except for certain proxy voting provisions which have an applicability date of one year following publication.

Below is a table summarizing key updates:

Key Provisions	Notes
Fiduciaries May (But Are Not Required To) Consider ESG Factors	The final rule states that a fiduciary’s duty of prudence must be based on factors that the fiduciary reasonably determines are relevant to a risk and return analysis and that such factors may include the economic effects of climate change and other ESG considerations. The DOL removed language from the 2021 proposed rule that had stated that fiduciary consideration “may often require” an evaluation of the economic effects of ESG factors, in response to comments that the language could be interpreted as a mandate to consider ESG factors. Instead, the final rule makes clear that a fiduciary may exercise discretion in determining the relevance of any factor to a risk-return analysis of an investment. The final rule eliminates the use of the term “pecuniary,” which was in the 2020 rule.
No Special Restrictions on QDIA Selection	The final rule removes the special restrictions that applied to ESG strategies in Qualified Default Investment Alternatives (QDIAs) under the 2020 rule, and makes clear that the same fiduciary standard applies to the selection of QDIA investments as to all other plan investments.
Collateral Benefits as Tiebreakers	The final rule retains a “tiebreaker” test, which allows fiduciaries to consider collateral benefits as tiebreakers under certain circumstances, and makes significant changes to the tiebreaker test in the 2020 rule. While the 2020 rule required that competing investments be “economically indistinguishable,” the final rule applies a standard that the competing investments “equally serve the financial interests of the plan over the appropriate time horizon.” The DOL noted comments received that the “economically indistinguishable” standard would effectively require investments to be precisely identical, while in fact competing investments may differ in their range of attributes but, when considered in totality, may serve the financial interests of the plan equally well. The final rule also removes the special documentation requirement applicable to the use of tiebreakers from the 2020 rule.
Taking Participant Preferences Into Account	The final rule adds a new provision indicating that plan fiduciaries do not violate their duty of loyalty solely because they take participants’ non-financial preferences into account when constructing a defined contribution plan menu in a manner that complies with the duty of prudence. The preamble states that while accommodating participants’ preferences may lead to greater participation and higher deferral rates (which could lead to greater retirement security), plan fiduciaries may not add imprudent options to menus just because participants request or would prefer them.
Proxy Voting and Shareholder Engagement	With respect to the exercise of shareholder rights, the final rule retains the core principle that the fiduciary duty to manage plan assets includes the management of shareholder rights such as the right to vote proxies. The final rule removes two “safe harbor” examples from the 2020 rule that the DOL believes encouraged abstention from voting. The final rule also removed specific requirements from the 2020 rule on maintaining records related to proxy voting on the basis that the language appeared to treat proxy voting differently from other fiduciary activities. Like the 2021 proposed rule, the final rule includes provisions regarding fiduciary duties relating to the use of proxy advisory firms and the treatment of proxy voting policies when investing in pooled investment funds.

The final rule added a provision that allows plan fiduciaries to take into consideration participant preferences when selecting options for an ERISA plan. While accommodating participants’ preferences may lead to greater participation and higher deferral rates (which could lead to greater retirement security), plan fiduciaries may not add imprudent options to menus just because participants request or would prefer them.

How important is it that your retirement savings incorporate ESG strategies?

Key Insights:

52% of working respondents indicate that incorporating ESG strategies in their retirement savings is important. (extremely, very, or moderately)

What ESG strategies would you be most interested to invest? (Select all that apply)

Source: Goldman Sachs Asset Management 2022 Retirement Survey. Our findings are from 1,566 individuals surveyed in July and August 2022 and provide insights from a diverse set of perspectives, including (i) working individuals (967 working individuals across generations—working Baby Boomers, Generation X, Millennials, and Generation Z), (ii) retired individuals (599 retired individuals aged 50-75) and (iii) gender and generational breakdowns for both populations. For more information, please see Goldman Sachs Asset Management’s report from October 2022 titled Retirement Survey & Insights Report 2022: Navigating the Financial Vortex.

Key Insights:

Of the 70% of respondents who indicate a preference to invest in ESG strategies, preferences were roughly balanced across climate-related strategies, fair worker practices and community-focused businesses.

In Focus: SECURE Act 2.0

On December 29, 2022, SECURE Act 2.0 was signed into law as part of the Consolidated Appropriations Act of 2023. SECURE 2.0 has a broad range of new provisions (90+ in total) and includes significant changes designed to help close existing gaps across the retirement system. Certain provisions reflect how competing financial responsibilities are interconnected with retirement savings and provide new mechanisms to help individuals manage pressing financial needs within their retirement plan. For more information on SECURE 2.0, see our summary report.

Key Provisions	Notes
Student loan match eligibility	Plan sponsors in 401(k), 403(b) and governmental 457(b) plans can make matching contributions to employees for “qualified student loan payments” made by the employee to pay qualified higher education expenses.
Emergency savings account linked to retirement plans	Individual account plans can offer non-highly compensated employees emergency savings accounts linked to their plan. Contributions are capped at $2,500 (or lower as set by the employer). Contributions are made on a Roth after-tax basis and are treated as elective deferrals for purposes of matching contributions (matches are not made in the emergency savings account) Participants can be auto-enrolled at no more than 3% of their salary Amounts must be able to be withdrawn at least once a month; the first four withdrawals each year may not be subject to fees. Contributions must be invested in cash, interest bearing deposits or principal preservation accounts
Employer contributions may be treated as Roth contributions	Plans may permit participants to designate employer matching or non-elective contributions as Roth contributions (if fully vested when made).
Saver’s Match	Changes the saver’s credit to a government matching contribution to an individual’s retirement plan or IRA. The pre-tax match is generally up to 50% of contributions (with income phase-outs), based on a maximum contribution eligible for a match of $2,000 per individual.
Automatic portability	Statutory exemption under Section 4975 of the Internal Revenue Code for transactions involving auto-portability services where a participant’s default IRA is automatically transferred to the participant’s new employer retirement plan (subject to an opt-out). The exemption is subject to a number of conditions and additional guidance from the DOL.
Unenrolled participants	Eliminates requirement for plan sponsors to send intermittent notices to unenrolled participants who have not elected to participate in a plan; requires an annual notice of eligibility during annual enrollment and providing any document so entitled upon request.
Qualifying longevity annuity contracts (QLACs)	Expands availability of QLACs by: Allowing QLAC premiums up to $200,000 (indexed) rather than $125,000 (indexed) and repealing the 25% limit Allowing QLACs to include certain spousal survival rights Providing up to 90-day “free-look” period
Removal of RMD barriers to lifetime income	Modifies the RMD rules to address certain barriers to the availability of lifetime annuity features in retirement plans, such as certain lump sum payments and annual payment increases at a modest rate for commercial annuities.
Small employer plan startup credits	Increases credit to 100% of qualified start-up costs for employers with up to 50 employees. Provides a new credit for 5 years of up to $1,000 per employee based on a percentage of employer contributions (other than for defined benefit plans) (with phase-outs for employers between 51-100 employees). Contributions to employees with wages greater than $100,000 are not included.
Starter 401(k) plans	Starter 401(k) plan type intended for employers not currently offering a retirement plan. Features include: Required auto-enrollment at a minimum of 3% deferral rate Contributions capped at $6,000 with an additional $1,000 beginning at age 50

SECURE Act 2.0 effective dates range from immediate to seven years after the date of enactment. The below illustration provides an overview of certain provision and their effective dates. The deadline for plan amendments to reflect the bill’s changes is generally the last day 2025 plan year.

Effective for 2023:

Enhanced start-up credit for new small employer plans
Rothification of match and non-electives contributions
Increase in RMD age (from age 72 to 73)
Qualified Longevity Annuity Contract revisions (regulations within 18 months)
Small financial incentives for contributing to a plan
Notices to unenrolled participants
Self-certification for hardship
Removing RMD barriers for life annuities
Reducing 50% penalty tax on late RMDs (from 50% to 25%)
IRA charitable distribution one-time election
Start-up credit available to those who join a MEP
Terminally ill distribution tax penalty exemption
PEP trustee duty modification
403b plans can join MEPs/PEPs
Annual audit requirement for group of plans
Recovery of retirement overpayments
Repayment of qualified birth or adoption distribution limited to three years

Effective for 2024:

Student loan match eligibility
Emergency savings account
Emergency distribution provision (up to $1000 per year)
Catch-up required to be converted to Roth
Auto-portability
Rollover of Excess 529 assets to Roth IRA
Domestic abuse related distributions
Conforming 403b and 401(k) hardship rules
Roth 401(k) exempt from RMD requirements
Starter 401(k) plans
New cash out limit (from $5k to $7k)
Indexing IRA catch-up limit
Surviving Spouse can elect to be treated as employee for purposes of RMDs
Performance benchmarks for asset allocation funds (regulations within 2 years)
New lost and found database (within 2 years after enactment)

Effective for 2025:

Automatic enrollment required for new plans
Higher catch-up limit for those age 60 – 63
Long-term part-time workers reduction to two years
LTC contracts purchased with retirement plan distributions (3 years after enactment)

Effective for 2026:

Annual paper statement requirement

Effective for 2027:

New Savers Match

Effective for 2028:

Certain ESOP provisions

Effective for 2029:

Insurance-dedicated ETFs

Retroactive Provisions

Start-up credit available to those who join a MEP (to 2020)
Qualified federally declared disasters rules (to 1/26/2021)

Source: Goldman Sachs Asset Management. For discussion purposes only. This is not a comprehensive list of all SECURE 2.0 provisions and is intended to cover the primary provisions for corporate defined contribution clients. As of January 13, 2023. “RMD” stands for Required Minimum Distribution. “IRA” stands for individual retirement account. “MEP” stands for Multiple Employer Plan. “PEP” stands for Pooled Employer Plan. “ESOP” stands for Employee Stock Ownership Plan. “Insurance-dedicated ETFs” refer to exchange-traded funds that will be available through individual variable annuities.

Insights: Women & Retirement Security

Women & Retirement Security, takes a deeper look at the gender differences from both working and retired Americans to better understand the challenges women face on their retirement journeys.

There are many headwinds unique to women saving and preparing for retirement. While women control one third of total US household financial assets ($10.9 trillion)¹ and comprise 47% of the workforce,² they earn 21% lower lifetime income than men.³ Part of this disparity is due to women on average having nine years’ less earned income, which affects their Social Security benefit⁴ and their retirement savings.

Women must also navigate the added complexity of longer life expectancy, putting more pressure on their retirement finances.

We evaluate survey responses from both working and retired Americans to understand the realities of preparing for and living in retirement that women face. Our goal is to identify the financial obstacles women are encountering and the lessons individuals and plan sponsors can apply. Women & Retirement Security includes key findings that we hope will help plan advisors and plan sponsors offer programs that better prepare women for a secure retirement.

Our findings are from 1,566 individuals surveyed in July and August 2022 and provide insights from a diverse set of perspectives, including (i) working individuals (967 working individuals across generations—working Baby Boomers, Generation X, Millennials, and Generation Z), (ii) retired individuals (599 retired individuals aged 50–75) and (iii) gender and generational breakdowns for both populations.

Key Survey Findings

Women and Retirement

RETIRED WOMEN REPORT RECEIVING LESS THAN 70% OF THEIR PRE-RETIREMENT INCOME IN RETIREMENT

Eight in ten retired women report their total annual income is less than 70% of their pre-retirement income.

Having access to a plan that provides personalized guidance on savings and investment strategy that can adjust and recalibrate through life events can help individuals better reach retirement with sufficient savings to maintain their standard of living.

FINANCIAL VORTEX HAS GREATER IMPACT ON WOMEN’S ABILITY TO SAVE FOR RETIREMENT

The women’s retirement savings are impacted more than men across all competing financial factors evaluated.

The financial vortex is a combination of competing financial priorities, life events and planning assumptions. Though women juggle the same types of financial responsibilities as men, more women report that these factors impact their ability to save for retirement.

WOMEN MORE LIKELY TO RETIRE EARLIER THAN PLANNED

More than 60% of women stated that they retired earlier than planned and 66% retired for reasons outside their control.

Not reaching one's desired retirement age can add pressure on existing savings to last longer than expected. The majority of women respondents faced this risk and are more likely than men respondents to retire early because of external factors like health and taking care of a family member.

WOMEN MORE LIKELY TO MANAGE THEIR OWN SAVINGS

Despite concerns about their ability to manage retirement savings, 69% of women use a self-directed approach.

Women report they are anxious and concerned about their ability to save for retirement, yet almost 70% of women respondents manage their own savings. This does not reflect their desire for help and advice, which is higher than reported by men.

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Defined Contribution Quarterly | 1Q 2023

Related Insights

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January 6, 2023 | GSAM Featured Insights
Secure Act 2.0 of 2022
January 6, 2023 On December 29, 2022, SECURE Act 2.0 was signed into law as part of the Consolidated Appropriations Act of 2023. SECURE 2.0 has a broad range of new provisions (92 in total), which include significant changes designed to help close existing gaps across the retirement system. We expand on these and several others in the rest of this report. Read More
Women & Retirement Security
December 7, 2022 This year’s Retirement Survey & Insights Report highlighted the challenges that working and retired individuals face as they save and invest for their retirement, especially in today's environment. The report shared detailed insights on prominent retirement trends experienced by generation and outlined potential difficulties these age groups may face on their retirement journey. In this supplemental report, we explore the gender differences in both working and retired Americans to better understand the challenges women face on their retirement journey. Read More

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¹ Source: Goldman Sachs’s EmpowerTM the Female Investor Advisor Seminar. Strategic Advisory Solutions. As of: October 19, 2021.

² Source: U.S. Bureau of Labor Statistics, Report 1097. As of March 2022.

³ Source: Senate Joint Economic Committee, “Gender Pay Inequality, Consequences for Women, Families, and the Economy.” 2016.

⁴ Source: Administration for Community Living, “2018 Profile of Older Americans.” May 31, 2019.

Quarterly Snapshot Source:

Goldman Sachs Asset Management. As of January 13, 2023. There is no guarantee that objectives will be met. “BBG” refers to Bloomberg. “HY” refers to High Yield. “Comm” refers to Commodities. “Cap” refers to capitalization. “EM” refers to Emerging Market. “Hybrid” funds invest in a mix of equities and fixed-income securities. The bulk of lifecycle and lifestyle funds is counted in this category. Please refer to the disclosures for additional definitions.

Glossary

A 401(k) plan is an employer-sponsored, tax advantaged retirement savings plan. 401(k)s are largely self-directed: Plan participants decide how much they would like to contribute from their salary, and which investments from among those offered by the plan they would like to invest in.

A 403(b) plan, sometimes known as a tax-sheltered annuity (TSA) or a tax-deferred annuity (TDA), is an employer-sponsored retirement savings plan for employees of not-for-profit organizations, such as colleges, hospitals, foundations and cultural institutions. Some employers offer 403(b) plans as a supplement to—rather than a replacement for—defined benefit pensions.

A 457 plan is a tax-deferred retirement savings plans are available to state and municipal employees. Like traditional 401(k) and 403(b) plans, the money you contribute and any earnings that accumulate in your name are not taxed until you withdraw.

Active Management refers to an investment approach where managers select investments for a portfolio in an attempt to outperform the benchmark index.

Volatility is a measure of variation of a financial instrument's price.

Risk Considerations

Environmental, Social and Governance (“ESG”) strategies may take risks or eliminate exposures found in other strategies or broad market benchmarks that may cause performance to diverge from the performance of these other strategies or market benchmarks. ESG strategies will be subject to the risks associated with their underlying investments’ asset classes. Further, the demand within certain markets or sectors that an ESG strategy targets may not develop as forecasted or may develop more slowly than anticipated.

All investing is subject to risk, including the possible loss of the money you invest.

Target Date Funds are subject to the risks associated with the underlying funds in which they invest. These risks change over time as the fund’s asset allocation strategy adjusts as it approaches its target date. There is no assurance any target date fund will achieve its investment objective. The principal value of an investment in a target date fund is not guaranteed at any time including at its target date.

Mutual funds are subject to various risks, as described fully in each Fund’s prospectus. There can be no assurance that the Funds will achieve their investment objectives. The Funds may be subject to style risk, which is the risk that the particular investing style of the Fund (i.e., growth or value) may be out of favor in the marketplace for various periods of time.

You could lose money by investing in a money market fund. An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Money market funds are not subject to credit risk, but will have interest rate risk. Institutional money market funds may have floating net asset values, and will fluctuate depending on market conditions. The Fund’s sponsor has no legal obligation to provide financial support to a money market fund, and you should not expect that the sponsor will provide financial support to the money market fund at any time.

Equity securities are more volatile than fixed income securities and subject to greater risks. Small and mid-sized company stocks involve greater risks than those customarily associated with larger companies.

International securities entail special risks such as currency, political, economic, and market risks.

Emerging markets securities may be less liquid and more volatile and are subject to a number of additional risks, including but not limited to currency fluctuations and political instability.

Bonds are subject to interest rate, price and credit risks. Prices tend to be inversely affected by changes in interest rates.

Investments in fixed-income securities are subject to credit and interest rate risks. Bond prices fluctuate inversely to changes in interest rates. Therefore, a general rise in interest rates can result in the decline in the bond's price. Credit risk is the risk that an issuer will default on payments of interest and principal. This risk is higher when investing in high yield bonds, also known as junk bonds, which have lower ratings and are subject to greater volatility. All fixed income investments may be worth less than their original cost upon redemption or maturity.

High yield fixed income securities are considered speculative, involve greater risk of default, and tend to be more volatile than investment grade fixed income securities.

Investments in foreign securities entail special risks such as currency, political, economic, and market risks. These risks are heightened in emerging markets.

An investment in real estate securities is subject to greater price volatility and the special risks associated with direct ownership of real estate.

Investments in commodities may be affected by changes in overall market movements, commodity index volatility, changes in interest rates or factors affecting a particular industry or commodity.

The above are not an exhaustive list of potential risks. There may be additional risks that should be considered before any investment decision.

General Disclosures

The views expressed herein are as of January 13, 2023, and subject to change in the future. Individual portfolio management teams for Goldman Sachs Asset Management may have views and opinions and/or make investment decisions that, in certain instances, may not always be consistent with the views and opinions expressed herein.

Views and opinions expressed are for informational purposes only and do not constitute a recommendation by Goldman Sachs Asset Management to buy, sell, or hold any security, they should not be construed as investment advice.

This material is provided for educational purposes only and should not be construed as investment advice or an offer or solicitation to buy or sell securities.

THESE MATERIALS ARE PROVIDED SOLELY ON THE BASIS THAT THEY WILL NOT CONSTITUTE INVESTMENT ADVICE AND WILL NOT FORM A PRIMARY BASIS FOR ANY PERSON’S OR PLAN’S INVESTMENT DECISIONS, AND GOLDMAN SACHS IS NOT A FIDUCIARY WITH RESPECT TO ANY PERSON OR PLAN BY REASON OF PROVIDING THE MATERIAL OR CONTENT HEREIN. PLAN FIDUCIARIES SHOULD CONSIDER THEIR OWN CIRCUMSTANCES IN ASSESSING ANY POTENTIAL INVESTMENT COURSE OF ACTION.

Past performance does not guarantee future results, which may vary. The value of investments and the income derived from investments will fluctuate and can go down as well as up. A loss of principal may occur.

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Economic and market forecasts presented herein reflect a series of assumptions and judgments as of the date of this document and are subject to change without notice. These forecasts do not take into account the specific investment objectives, restrictions, tax and financial situation or other needs of any specific client. Actual data will vary and may not be reflected here. These forecasts are subject to high levels of uncertainty that may affect actual performance. Accordingly, these forecasts should be viewed as merely representative of a broad range of possible outcomes. These forecasts are estimated, based on assumptions, and are subject to significant revision and may change materially as economic and market conditions change. Goldman Sachs has no obligation to provide updates or changes to these forecasts. Case studies and examples are for illustrative purposes only.

Any reference to a specific company or security does not constitute a recommendation to buy, sell, hold or directly invest in the company or its securities. It should not be assumed that investment decisions made in the future will be profitable or will equal the performance of the securities discussed in this document.

This information discusses general market activity, industry or sector trends, or other broad-based economic, market or political conditions and should not be construed as research or investment advice. This material has been prepared by Goldman Sachs Asset Management and is not financial research nor a product of Goldman Sachs Global Investment Research (GIR). It was not prepared in compliance with applicable provisions of law designed to promote the independence of financial analysis and is not subject to a prohibition on trading following the distribution of financial research. The views and opinions expressed may differ from those of Goldman Sachs Global Investment Research or other departments or divisions of Goldman Sachs and its affiliates. Investors are urged to consult with their financial advisors before buying or selling any securities. This information may not be current and Goldman Sachs Asset Management has no obligation to provide any updates or changes.

Index Benchmarks

Indices are unmanaged. The figures for the index reflect the reinvestment of all income or dividends, as applicable, but do not reflect the deduction of any fees or expenses which would reduce returns. Investors cannot invest directly in indices. The indices referenced herein have been selected because they are well known, easily recognized by investors, and reflect those indices that the Investment Manager believes, in part based on industry practice, provide a suitable benchmark against which to evaluate the investment or broader market described herein.

Bloomberg US Aggregate Bond Index represents an unmanaged diversified portfolio of fixed income securities, including US Treasuries, investment grade corporate bonds, and mortgage backed and asset-backed securities.

Bloomberg US High Yield Index covers the universe of fixed rate, non-investment grade debt.

Bloomberg US Long Government/Credit Index is a broad-based flagship benchmark that measures the non-securitized component of long maturity (10+ years) bonds in the US Aggregate Bond Index. It includes investment grade, US dollar-denominated, fixed-rate Treasuries, government-related and corporate securities.

MSCI EAFE Index is a market capitalization weighted composite of securities in 21 developed markets.

MSCI Emerging Markets Equity Index is a free float-adjusted market capitalization index that is designed to measure equity market performance of emerging markets.

Russell 1000 Growth Index is an unmanaged index that measures the performance of the large cap growth segment of the US equity universe.

Russell 1000 Value Index is an unmanaged index of common stock prices that measures the performance of the large cap value segment of the US equity universe.

Russell 2000 Growth Index is an unmanaged index of common stock prices that measures the performance of the small cap growth segment of the US equity universe.

Russell 2000 Index measures the performance of the small-cap segment of the US equity universe. The Russell 2000 Index is a subset of the Russell 3000 Index representing approximately 10% of the total market capitalization of that index. It includes approximately 2000 of the smallest securities based on a combination of their market cap and current index membership.

Russell 2000 Value Index is an unmanaged index of common stock prices that measures the performance of the small cap value segment of the US equity universe.

S&P 500 Index is the Standard & Poor’s 500 Composite Stock Prices Index of 500 stocks, an unmanaged index of common stock prices.

S&P GSCI Commodity Index is a composite index of commodity sector returns, representing an unleveraged, long-only investment in commodity futures that is broadly diversified across the spectrum of commodities.

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Goldman Sachs Asset Management (Hong Kong) Limited (GSAMHK), pursuant to ASIC Class Order 03/1103 and Goldman Sachs (Asia) LLC (GSALLC), pursuant to ASIC Instrument 04/0250; regulated by the Securities and Futures Commission of Hong Kong under Hong Kong laws.

No offer to acquire any interest in a fund or a financial product is being made to you in this document. If the interests or financial products do become available in the future, the offer may be arranged by GSAMA in accordance with section 911A(2)(b) of the Corporations Act. GSAMA holds Australian Financial Services Licence No. 228948. Any offer will only be made in circumstances where disclosure is not required under Part 6D.2 of the Corporations Act or a product disclosure statement is not required to be given under Part 7.9 of the Corporations Act (as relevant).

Canada: This document has been communicated in Canada by GSAM LP, which is registered as a portfolio manager under securities legislation in all provinces of Canada and as a commodity trading manager under the commodity futures legislation of Ontario and as a derivatives adviser under the derivatives legislation of Quebec. GSAM LP is not registered to provide investment advisory or portfolio management services in respect of exchange-traded futures or options contracts in Manitoba and is not offering to provide such investment advisory or portfolio management services in Manitoba by delivery of this material.

Japan: This material has been issued or approved in Japan for the use of professional investors defined in Article 2 paragraph (31) of the Financial Instruments and Exchange Law by Goldman Sachs Asset Management Co., Ltd.

Confidentiality

No part of this material may, without Goldman Sachs Asset Management’s prior written consent, be (i) copied, photocopied or duplicated in any form, by any means, or (ii) distributed to any person that is not an employee, officer, director, or authorized agent of the recipient.

Date of First Use: January 31, 2023.

Compliance code: 303731-OTU-1731215.